ADEQ MINOR SOURCE AIR PERMIT

ADEQ MINOR SOURCE AIR PERMIT Permit #: 1349-AR-2 IS ISSUED TO: FM Structural Plastic Technology, Inc. dba FM Corporation 3535 Hudson Road Rogers, AR 72757 Benton County THIS PERMIT IS FM CORPORATION s AUTHORITY TO CONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/OR FACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT S MINOR SOURCE AIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THE PROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT (ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATED THEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINED HEREIN. Signed: Michael Bonds Chief, Air Division Date

Table of Contents Section I: FACILITY INFORMATION... 3 Section II: INTRODUCTION... 4 Summary... 4 Process Description... 4 Regulations... 4 Section III: PERMIT HISTORY... 6 Section IV: EMISSION UNIT INFORMATION... 7 Specific Conditions... 7 Section V: INSIGNIFICANT ACTIVITIES... 14 Section VI: GENERAL CONDITIONS... 15 APPENDIX A (40 CFR 60, Subpart TTT)...19 2

Section I: FACILITY INFORMATION PERMITTEE: FM Structural Plastics Technology, Inc. dba FM Corporation PERMIT NUMBER: 1349-AR-2 FACILITY ADDRESS: 3535 Hudson Road Rogers, AR 72757 MAILING ADDRESS: P.O. Box 1720 Rogers, AR 72757-1720 COUNTY: Benton CONTACT POSITION: TELEPHONE NUMBER: (479)621-4614 Ellen Dey Industrial Engineer/Environmental Compliance Officer FAX NUMBER: (479)631-2392 REVIEWING ENGINEER: Paul Osmon UTM North-South (Y): Zone 15-4024.1 km N UTM East-West (X): Zone 15-395.1 km E 3

Section II: INTRODUCTION Summary FM Corporation operates a manufacturing plant located at 3535 Hudson Road in Rogers. FM Corporation makes a wide variety of plastic parts using a low-pressure structural-foam molding process. The company also produces other components using a direct injection molding process. Certain parts are painted, assembled and/or otherwise finished after their manufacture. This Minor Source air permit is issued as a replacement for their previous Title V air permit. Emissions at the facility have been reduced below the major source thresholds for both criteria pollutants and hazardous air pollutants. Process Description FM Structural Plastic Technologies, Inc. (FM Corporation) currently operates a manufacturing plant located in Rogers, Arkansas. Plastic parts and components are produced by utilizing two molding processes, structural-foam molding and direct injection molding. Following production, certain parts are painted, assembled and/or subjected to various other finishing processes. The production operations at the Rogers plant are categorized under North American Industrial Classification System (NAICS) Code 326199 (miscellaneous plastic products). FM Corporation in the previous permit was categorized as a major source due to emission of hazardous air pollutants (HAPs) that exceed both the 10 ton per year individual limit and the 25 ton per year total HAP limit. A majority of these emissions result from the paint booths (SN-01 through SN-06 and SN-11 through SN-18) that are used in the painting and finishing of the plastic parts. FM Corporation operates a natural gas fired drying oven (SN-20) that results in low levels of combustion emissions, and is considered insignificant due to the small size of the oven. Also included are facility-wide parts cleaning (SN-22) that causes emissions of VOC and tetrachloroethylene. Facility wide adhesive bonding operations (SN-23) cause emissions of VOC and several HAPs. Additionally, a small amount of particulate matter is emitted from a sanding operation (SN-19) used in between certain paint booths and it is considered to be insignificant. A series of paint booths (SN-07 through SN-09) and two drying ovens (SN-10 and SN-21) have been removed from the facility. FM Corporation will accept limits with this permit which establish them as a Minor Source with an emission limit for VOCs of less than 100 tons per year and hazardous air pollutants (HAPs) limits of less than 10 tpy for any single HAP and 25 tons per year for combined HAP. Regulations FM Corporation is subject to the Arkansas Plan of Implementation for Air Pollution Control (Regulation #19) and the Arkansas Air Pollution Control Code (Regulation #18). The new paint line (SN-11 through SN-18) at FM Corporation is subject to 40 CFR Part 60, Subpart TTT of the New Source Performance Standards (NSPS). The facility is required to keep records on all paint lines when painting office machines for compliance assurance with Subpart TTT. The facility has processes that are potentially subject to 40 CFR 63, Subpart MMMM, Surface Coating of Miscellaneous Metal Parts and Products and 40 CFR 63, Subpart PPPP, Surface Coating of Miscellaneous Plastic Parts and Products if they were a Major Source. Since the facility is now a Minor Source, they are not subject to these NESHAPs if they remain a Minor Source. 4

The following table is a summary of the facility=s total emissions. Table 1 - Total Allowable Emissions Total Allowable Emissions Pollutant Emissions Rates lb/hr tpy VOC 176.6 95.0 Total HAP 176.6 24.0 Single HAP 176.6 9.5 176.6 60.0 p-chlorobenzotriflouride 176.6 22.0 5

Section III: PERMIT HISTORY 1349-A Issued on October 20, 1994, this was the first operating permit issued to FM Corporation. It established the equipment and emission limits for the plastics manufacturer as a minor source. 1349-AR-1 1349-AOP-R0 1349-AOP-R1 This permit, issued on July 11, 1996, covered the addition of SN-11 through SN-21 and included the corresponding emission changes. This permit, issued on October 18, 1999, was the initial Title V permit for this facility. This permit listed FM Corporation as not being subject to 40 CFR Part 60, Subpart TTT because office machines were painted in paint booths installed prior to 1986 at that time. Permit limits for criteria pollutants were PM/PM 10-8.9 tpy and VOC - 237.5 tpy. This permit was issued on August 1, 2001. This permit established that the new paint line (SN-11 through SN-18) at FM Corporation is subject to 40 CFR Part 60, Subpart TTT of the New Source Performance Standards (NSPS). Permit limits for criteria pollutants were PM/PM 10 3.0 tpy and VOC 95.0 tpy. Total emission limit for total HAPs were 47.5 tpy. Emission limit for acetone was 43.5 tpy and for p-chlorobenzotrifluoride was 15.7 tpy. 6

Section IV: EMISSION UNIT INFORMATION Specific Conditions 1. The permittee will not exceed the emission rates set forth in the following table. [ 19.501 et seq. of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control, effective February 15, 1999 (Regulation 19) and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-311] Table 2 - Criteria Pollutants SN Description Pollutant lb/hr Tpy SN-01 Spray Paint Booth VOC 8.9 * SN-02 Spray Paint Booth VOC 8.9 * SN-03 Spray Paint Booth VOC 8.9 * SN-04 Spray Paint Booth VOC 8.9 * SN-05 Spray Paint Booth VOC 8.9 * SN-06 Spray Paint Booth VOC 8.9 * SN-07 SN-08 SN-09 SN-10 Sources Deleted SN-11 Spray Paint Booth VOC 8.9 * SN-12 Spray Paint Booth VOC 8.9 * SN-13 Spray Paint Booth VOC 8.9 * SN-14 Spray Paint Booth VOC 8.9 * SN-15 Spray Paint Booth VOC 8.9 * SN-16 Spray Paint Booth VOC 8.9 * SN-17 Spray Paint Booth VOC 8.9 * SN-18 Spray Paint Booth VOC 8.9 * SN-19 Sanding Booth Insignificant Activity SN-20 Drying Oven 2.75 MMBtu/hr Insignificant Activity SN-21 Source Deleted SN-22 Parts Cleaning Operations VOC 8.0 * SN-23 Adhesive Bonding Operations VOC 44.0 * SN-24 Paint Mixing Operations Accounted for in Paint Booths * - Plantwide Limit for VOC emissions is 95.0 tpy based on Specific Condition No. 3 7

2. The permittee will not exceed the emission rates set forth in the following table. [ 18.801 of the Arkansas Air Pollution Control Code, effective February 15, 1999 (Regulation 18), and A.C.A. 8-4-203 as referenced by '8-4-304 and 8-4-311] Table 3 - Non-Criteria Pollutants SN Description Pollutant lb/hr tpy SN-01 Spray Paint Booth Individual HAP SN-02 Spray Paint Booth Individual HAP SN-03 Spray Paint Booth Individual HAP SN-04 Spray Paint Booth Individual HAP SN-05 Spray Paint Booth Individual HAP SN-06 Spray Paint Booth Individual HAP SN-07 SN-08 SN-09 SN-10 Sources Deleted * * * * * * 8

SN Description Pollutant lb/hr tpy SN-11 Spray Paint Booth Individual HAP SN-12 Spray Paint Booth Individual HAP SN-13 Spray Paint Booth Individual HAP SN-14 Spray Paint Booth Individual HAP SN-15 Spray Paint Booth Individual HAP SN-16 Spray Paint Booth Individual HAP SN-17 Spray Paint Booth Individual HAP SN-18 Spray Paint Booth Individual HAP SN-19 Sanding Booth Insignificant Activity SN-20 Drying Oven 2.75 MMBtu/hr Insignificant Activity SN-21 Source Deleted * * * * * * * * 9

SN Description Pollutant lb/hr tpy SN-22 Parts Cleaning Operations Individual HAP SN-23 Adhesive Bonding Operations Individual HAP 8.0 8.0 8.0 8.0 44.0 44.0 44.0 44.0 * * SN-24 Paint Mixing Operations Accounted for in Paint Booths * - p-chlorobenzotriflouride CAS No. 98-56-6 - Plantwide Limit for HAP emissions is 9.5 tpy single HAP and 24.0 tpy total HAPs based on Specific Condition No. 4 * - Plantwide Limit for emissions is 60.0 tpy based on Specific Condition No. 5 - Plantwide Limit for CBTF emissions is 22.0 tpy based on Specific Condition No. 5 3. The permittee shall not exceed the Plantwide VOC emission limit of 95.0 tons per twelve month period. The permittee shall complete a monthly VOC usage material balance for the facility and a rolling 12-month summary shall be kept on-site and made available to the Department upon request. These records shall be updated by the 15 th of the following month. [ 19.705 of Regulation 19 and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-311] 4. The permittee shall not exceed the Plantwide HAP emission limit of 9.5 tons per twelve month period of a single HAP and 24.0 tons per year total combined HAPs. The permittee shall complete a monthly single HAP and total HAP usage material balance for the facility and a rolling 12-month summary shall be kept on site and made available to the Department upon request. These records shall be updated by the 15 th of the following month. [ 18.801 of Regulation 18, and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-31] 5. The permittee shall not exceed the Plantwide acetone emission limit of 60.0 tons per twelve month period and the Plantwide p-chlorobenzotriflouride emission limit of 22.0 tons per year. The permittee shall complete a monthly acetone and p-chlorobenzotriflouride usage material balance for the facility and a rolling 12-month summary shall be kept on-site and made available to the Department upon request. These records shall be updated by the 15 th of the following month. [ 18.801 of Regulation 18, and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-31] 10

6. The permittee shall not exceed a VOC content of 8.00 lb/gal in the paints, catalysts, solvents, and adhesive activator/ catalyst materials used at the facility. The permittee shall keep records which document compliance with this Specific Condition. These records shall be updated by the 15 th of the following month. [ 19.705 of Regulation 19 and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-311] 7. The permittee shall not exceed the maximum HAP and air contaminant content limits for any surface coatings, thinners, paint catalysts, cleaning solvents or adhesive activators/catalysts used at the facility as listed in the following table. The permittee shall keep records which document compliance with this Specific Condition. These records shall be updated by the 15 th of the following month. [ 18.1004 of Regulation 18, and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-31] Minimum Threshold Limit Values (TLVs) Versus Maximum Content Limits for Volatile HAPS,, and p-chlorobenzotriflouride. Minimum TLV (mg/m 3 ) Maximum Concentration of any HAP (lb/gal) 175.2 8.0 153.3 7.0 131.4 6.0 109.5 5.0 87.6 4.0 65.7 3.0 43.8 2.0 21.9 1.0 11.0 0.5 2.2 0.1 * - linear interpolations and extrapolations are allowed for this table. - limits also apply to air contaminants which have an established TLV. 11

8. The permittee will not cause or permit the emission of air contaminants, including odors or water vapor and including an air contaminant whose emission is not otherwise prohibited by Regulation #18, if the emission of the air contaminant constitutes air pollution within the meaning of A.C.A. 8-4-303. [ 18.801 of Regulation 18, and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-31] 9. The permittee will not conduct operations in such a manner as to unnecessarily cause air contaminants and other pollutants to become airborne. [ 18.901 of Regulation 18, and A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-311] 10. The permittee shall notify the Department when a Threshold Limit Value (TLV) for p- Chlorobenzotriflouride has been established by the American Conference of Governmental Industrial Hygienists (ACGIH). The permittee shall provide proof of compliance with the ADEQ Non-Criteria Pollutant Strategy for this compound within six months of promulgation of the final TLV. [A.C.A. 8-4-203 as referenced by 8-4-304 and 8-4-31] NSPS Requirements 11. The facility shall not cause the discharge into the atmosphere in excess of the following limits based on the formulas listed in '60.723 while painting plastic parts for business machines (business machine is defined in 40 CFR '60.721 (a)) : [ 19.304 of Regulation 19 and 40 CFR 60.722(a)] a. 1.5 kilograms of VOC=s per liter of coating solids applied from prime coating of plastic parts for business machines. b. 1.5 kilograms of VOC=s per liter of coating solids applied from color coating of plastic parts for business machines. c. 2.3 kilograms of VOC=s per liter of coating solids applied from texture coating of plastic parts for business machines. d. 2.3 kilograms of VOC=s per liter of coating solids applied from touch-up coating of plastic parts for business machines. If each individual coating used for painting office machine parts has a VOC content as received which when divided by the lowest transfer efficiency at which the coating is applied for each coating operation results in a value less than the above efficiencies, the facility is in compliance provided that no VOC=s are added to the coatings before application. 12. The facility shall complete a performance test for each nominal 1-month period for the facility proving compliance with Specific Condition No.119. [ 19.304 of Regulation 19 and 40 CFR 60.723(b)] 12

13. The permittee shall complete a monthly report which details the kilograms of VOC=s per liter of coatings solids applied for each coating operation. The permittee shall submit reports of non-compliance if it occurs on a quarterly basis. These reports shall be postmarked not later than 10 days after the period covered. Statements of compliance shall be submitted on a semi-annual basis. ['19.304 of Regulation 19 and 40 CFR '60.724 (b)] 14. The permittee shall maintain records at the source for two (2) years of all data and calculations used to determine monthly VOC emissions for each coating operation for each facility. ['19.304 of Regulation 19 and 40 CFR '60.724 (d)] 13

Section V: INSIGNIFICANT ACTIVITIES The Department deems the following types of activities or emissions as insignificant on the basis of size, emission rate, production rate, or activity in accordance with Group A of the Insignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activity emission determinations rely upon the information submitted by the permittee in an application dated April 19, 2004. Table 4 - Insignificant Activities Description Category Solvent Still * Paint Mix Room * Sanding Room Group A, No. 13 Sanding Booth (SN-19) Group A, No. 13 Plastic Shredder Machine Group A, No. 13 Natural Gas Fired Oven, 2.75 MMBtu/hr Group A, No. 1 Silk Screening Oven, 0.01 MMBtu/hr Group A, No. 1 Silk Screening Operation Group A, No. 13 Mixers, Blenders, and Rolling Mills for Plastic Group A, No. 13 Plastic Parts Molding Machinery Group A, No. 13 Application of Aerosol Mold Treatment Products Group A, No. 13 3 - Plural component paint mixing systems * * - accounted for with paint booth material balances. - vents inside building. 14

Section VI: GENERAL CONDITIONS 1. Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) as the sole origin of and authority for the terms or conditions are not required under the Clean Air Act or any of its applicable requirements, and are not federally enforceable under the Clean Air Act. Arkansas Pollution Control & Ecology Commission Regulation 18 was adopted pursuant to the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.). Any terms or conditions included in this permit that specify and reference Arkansas Pollution Control & Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution Control Act (A.C.A. '8-4-101 et seq.) as the origin of and authority for the terms or conditions are enforceable under this Arkansas statute. 2. This permit does not relieve the owner or operator of the equipment and/or the facility from compliance with all applicable provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated under the Act. [A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 3. The permittee will notify the Department in writing within thirty (30) days after commencement of construction, completion of construction, first operation of equipment and/or facility, and first attainment of the equipment and/or facility target production rate. [ 19.704 of the Regulations of the Arkansas Plan of Implementation for Air Pollution Control (Regulation 19) and/or A.C.A. 8-4-203 as referenced by A.C.A. 8-4-304 and 8-4-311] 4. Construction or modification must commence within eighteen (18) months from the date of permit issuance. ['19.410(B) of Regulation 19 and/or '18.309(B) of the Arkansas Air Pollution Control Code (Regulation 18) and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 5. The permittee must keep records for five years to enable the Department to determine compliance with the terms of this permit--such as hours of operation, throughput, upset conditions, and continuous monitoring data. The Department may use the records, at the discretion of the Department, to determine compliance with the conditions of the permit. ['19.705 of Regulation 19 and/or '18.1004 of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 6. A responsible official must certify any reports required by any condition contained in this permit and submit any reports to the Department at the address below. ['19.705 of Regulation 19 and/or '18.1004 of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 15

Arkansas Department of Environmental Quality Air Division ATTN: Compliance Inspector Supervisor Post Office Box 8913 Little Rock, AR 72219 7. The permittee will test any equipment scheduled for testing, unless stated in the Specific Conditions of this permit or by any federally regulated requirements, within the following time frames: (1) newly constructed or modified equipment within sixty (60) days of achieving the maximum production rate, but no later than 180 days after initial start-up of the permitted source or (2) existing equipment already operating according to the time frames set forth by the Department. The permittee must notify the Department of the scheduled date of compliance testing at least fifteen (15) days in advance of such test. The permittee must submit compliance test results to the Department within thirty (30) days after the completion of testing. ['19.702 of Regulation 19 and/or '18.1002 of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 8. The permittee will provide: [ 19.702 of Regulation 19 and/or '18.1002 of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] a. Sampling ports adequate for applicable test methods b. Safe sampling platforms c. Safe access to sampling platforms d. Utilities for sampling and testing equipment 9. The permittee will operate equipment, control apparatus and emission monitoring equipment within their design limitations. The permittee will maintain in good condition at all times equipment, control apparatus and emission monitoring equipment. ['19.303 of Regulation 19 and/or '18.1104 of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 10. If the permittee exceeds an emission limit established by this permit, the permittee will be deemed in violation of said permit and will be subject to enforcement action. The Department may forego enforcement action for emissions exceeding any limits established by this permit provided the following requirements are met: ['19.601 of Regulation 19 and/or '18.1101 of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] a. The permittee demonstrates to the satisfaction of the Department that the emissions resulted from an equipment malfunction or upset and are not the result of negligence or improper maintenance, and the permittee took all reasonable measures to immediately minimize or eliminate the excess emissions. 16

b. The permittee reports the occurrence or upset or breakdown of equipment (by telephone, facsimile, or overnight delivery) to the Department by the end of the next business day after the occurrence or the discovery of the occurrence. c. The permittee must submit to the Department, within five business days after the occurrence or the discovery of the occurrence, a full, written report of such occurrence, including a statement of all known causes and of the scheduling and nature of the actions to be taken to minimize or eliminate future occurrences, including, but not limited to, action to reduce the frequency of occurrence of such conditions, to minimize the amount by which said limits are exceeded, and to reduce the length of time for which said limits are exceeded. If the information is included in the initial report, the information need not be submitted again. 11. The permittee shall allow representatives of the Department upon the presentation of credentials: [A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] a. To enter upon the permittee's premises, or other premises under the control of the permittee, where an air pollutant source is located or in which any records are required to be kept under the terms and conditions of this permit; b. To have access to and copy any records required to be kept under the terms and conditions of this permit, or the Act; c. To inspect any monitoring equipment or monitoring method required in this permit; d. To sample any emission of pollutants; and e. To perform an operation and maintenance inspection of the permitted source. 12. The Department issued this permit in reliance upon the statements and presentations made in the permit application. The Department has no responsibility for the adequacy or proper functioning of the equipment or control apparatus. [A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 13. The Department may revoke or modify this permit when, in the judgment of the Department, such revocation or modification is necessary to comply with the applicable provisions of the Arkansas Water and Air Pollution Control Act and the regulations promulgated the Arkansas Water and Air Pollution Control Act. ['19.410(A) of Regulation 19 and/or '18.309(A) of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 14. This permit may be transferred. An applicant for a transfer must submit a written request for transfer of the permit on a form provided by the Department and submit the disclosure statement required by Arkansas Code Annotated '8-1-106 at least thirty (30) days in advance of the proposed transfer date. The permit will be automatically transferred to the new permittee unless the Department denies the request to transfer within thirty (30) days of 17

the receipt of the disclosure statement. The Department may deny a transfer on the basis of the information revealed in the disclosure statement or other investigation or, deliberate falsification or omission of relevant information. ['19.407(B) of Regulation 19 and/or '18.307(B) of Regulation 18 and A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 15. This permit shall be available for inspection on the premises where the control apparatus is located. [A.C.A. '8-4-203 as referenced by A.C.A. '8-4-304 and '8-4-311] 16. This permit authorizes only those pollutant emitting activities addressed herein. [A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311] 17. This permit supersedes and voids all previously issued air permits for this facility. [Regulation 18 and 19 and A.C.A. '8-4-203 as referenced by '8-4-304 and '8-4-311] 18. The permittee must pay all permit fees in accordance with the procedures established in Regulation No. 9. [A.C.A 8-1-105(c)] 18

APPENDIX A 40 CFR 60, SUBPART TTT